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Filing # 157780593 E-Filed 09/20/2022 02:26:55 PM
IN THE CIRCUIT COURT OF THE EIGHTH
JUDICIAL CIRCUIT, IN AND FOR UNION
COUNTY, FLORIDA
case No.: 3-AOAD-CA-OOSS
MARK A. LINK AND JOHN C. HAHN,
PLAINTIFF(S),
Vs.
MICHAEL W. BANGERT,
DEFENDANT(S)
VERIFIED COMPLAINT FOR PARTITION
COMES NOW the Plaintiffs, MARK A. LINK and JOHN C. HAHN, by and through their
undersigned counsel, and hereby file this Verified Complaint for Partition against the Defendant,
MICHAEL W. BANGERT and allege as follows:
4 This is an action for partition of real property that exceeds the sum of $30,000.00
in value.
2. This Court has jurisdiction pursuant to §64.011, Fla. Stat., and venue is proper
in Union County, Florida, where the real property is situated.
3. The real property (“Property”) that is the subject of this action is located in
Union County, Florida, and is more particularly described as follows:
3701 SW 94th Place, Lake Butler, FL 32054:
Parcel No.:36-06-18-52-000-0070-0:
Exhibit “A” attached hereto and made a part hereof by reference.
Title to the Property is owned as follows:
Owner Ownership Interest*
MARK A. LINK and JOHN C. HAHN 2/3
MICHAEL W. BANGERT 113
Electronically Filed Union Case # 22000055CAD KM 09/20/2022 02:26:55 PM
5. MARK A. LINK, JOHN C. HAHN, and MICHAEL W. BANGERT jointly own the
Property as tenants in common as evidenced by the Speciall Warranty Deed attached hereto as
Exhibit “A”.
6. MARK A. LINK and JOHN C. HAHN currently reside at 3754 SW 99th Place, Lake
Butler, FL 32054 and 110 S. Shore Lane, Crescent City, FL 32112, respectively.
7. To the best knowledge of the Plaintiffs, MICHAEL W. BANGERT currently resides
at 3701 SW 94th Place, Lake Butler, FL 32054.
8. Plaintiffs request that this Court partition the Property in accordance with the
foregoing ownership interest.
9. In the event the Court determines that the Property is non-di ible, Plaintiffs
request that the Property be sold by private sale and that the proceeds therefrom be split between
the parties pursuant to the respective ownership interest and applicable equitable adjustments.
10. Plaintiffs have incurred other expenses in connection with the preservation and
maintenance of the Property and therefore Plaintiffs request an accounting so that special equities
are considered in allocating the division of the Property or the proceeds therefrom.
11. Plaintiffs have retained the undersigned firm Curtis Law Firm, LLC, and have
agreed to pay a reasonable fee for their services.
12. Pursuant to §64.081 Fla. Stat., Plaintiffs are entitled to their reasonable
attorney’s fees and costs incurred in this action.
WHEREFORE, Plaintiffs MARK A. LINK and JOHN C. HAHN respectfully request this
Court enter an order:
A Requiring the Property be partitioned or if the Court determines it is not
divisible that the Property be sold via private sale;
B Appointing a magistrate or other qualified neutral party to conduct the sale
of the Property if required;
Cc Allocating the Property or proceeds of sale in proportion to the parties’
respective interests, subject to special equities that may be shown;
D. Awarding Plaintiffs their reasonable attomey’s fees and costs;
E Awarding Plaintiffs any further relief deemed appropriate and just.
Page 2 of 8
Respectfully submitted this 20th day of September 2022.
CURTIS LAW FIRM, LLC
/s/ Ryan C. Curtis, Esq.
Ryan C. Curtis, Esquire
Florida Bar Number 0163589
175 N.W. 138" Terr., Suite 100
Jonesville, Florida 32669
(352) 333-7207
(352) 331-0818 (facsimile)
Service: rcurtis@curtisiawfirm.net
Attorney for Plaintiffs
COMPLAINT VERIFICATION
Under penalty of perjury, | declare that | have read the foregoing, and the facts alleged
therein are true and correct to the best of my knowledge and belief.
Oe JOHN C. HAHN
WARKHA. LINK
(LECP Ze
Q-1G- 22
‘Date
Daie
Page 3 of 8
SPECIAL WARRANTY DEED
EXHIBIT A
LOT 7:
APARCEL OF LAND LYING IN AND BEING A PART OF SECTION 36; TOWNSHIP 6 SOUTH, RANGE
18 EAST, UNION COUNTY, FLORIDA, DESCRIBEDAS FOLLOWS:
COMMENCE AT THE NORTHWEST CORNER, OF SAID SECTION 36; THENCE NORTH 86
DEGREES 46 MINUTES 14 SECONDS EAST ALONG THE NORTH LINE OF SAID SECTION 36 FOR
A DISTANCE OF 1901.74 FEET TO THE POINT OF BEGINNING OF THE HEREIN DESCRIBED
PARCEL; THENCE CONTINUE NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST FOR A
DISTANCE OF 130.00 FEET; THENCE SOUTH 03 DEGREES, 13 MINUTES 56 SECONDS EAST FOR
ADISTANCE OF 775 FEET TO THE THREAD OF THE SANTAFE RIVER; THENCE MEANDER
SOUTHWESTERLY ALONG SAID THREAD OF THE SANTA FE RIVER TO A POINT WHICH BEARS
SOUTH 04 DEGREES 37 MINUTES 32 SECONDS EAST FROM THE POINT OF BEGINNING
THENCE NORTH 04 DEGREES 37 MINUTES 32 SECONDS WEST FOR A DISTANCE OF 835 FEET,
MORE OR LESS, TO THE POINT OF BEGINNING. CONTAINING 2.22 ACRES, MORE OR LESS.
SUBJECT TO AN EASEMENT FOR ROAD PURPOSE’S ACROSS THE NORTH 20 FEET THEREOF.
TOGETHER, WITH A PERPETUAL NONEXCLUSIVE EASEMENT FOR INGRESS AND EGRESS
BEING 40 FEET WIDE LYING, BEIN' IG AND SITUATE IN SECTIONS 25 AND 36, TOWNSHIP 6
SOUTH, RANGE 18 EAST, AND IN SECTION 30, TOWNSHIP 6 SOUTH, RANGE 19 EAST, UNION
COUNTY, FLORIDA, MORE PARTICULARLY
DESCRIBED AS FOLLOWS:
COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION 30, THENCE RUN NORTH 88A
DEGREES 26 MINUTES 15 SECONDS EAST, ALONG THE NORTH LINE OF SAID SECTION 30,
DISTANCE OF 116.51 FEET; THENCE RUN SOUTH 02 DEGREES 31 MINUTES 40 SECONDS EAST
AND
A DISTANCE OF 83.69 FEET TO THE SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18
OF BEGINNIN G OF THE HEREINAF TER DESCRIBE D EASEMEN T; THENCE CONTINUE
THE POINT
RUNNING SOUTH 02 DEGREES 31 MINUTES 40 SECONDS EAST A DISTANCE, OF 1114.59 FEET;
THENCE RUN SOUTH 42 DEGREES 04 MINUTES 27 SECONDS WEST A DISTANCE OF 166.73
FEET TO THE SOUTHWEST CORNER OF THE WEST 1/2 OF NORTHWEST 1/4 OF NORTHWEST
1/4 OF SAID SECTION 30; THENCE CONTINUE RUNNING SOUTH 42 DEGREES 04 MINUTES 27
SECONDS WEST A DISTANCE, OF 55.82 FEET; THENCE RUN SOUTH 83 DEGREES 44 MINUTES
02 SECONDS WEST A DISTANCE OF 276.04 FEET TO THE POINT OF CURVATURE OF A CURVE
CONCAVE
TO THE LEFT; THENCE RUN SOUTHWESTERLY ALONG THE ARC OF SAID CURVE, ANGLE OF 80
SOUTHEASTERLY WITH A RADIUS OF 100.00 FEET, THROUGH A CENTRAL
E OF 139.69 FEET TO A POINT OF
DEGR' fES 02 MINUTES 19 SECONDS AN ARC DISTANC
TANGENCY, THENC! RUN SOUTH 03 DEGREE S 41 MINUTES 43 SECOND S WEST A DISTANCE
OF 353.51 FEET, THENCE RUN S' OUTH 08 DEGREE S 05 MINUTE S 37 SECOND S WEST A
MINUTE S; 35 SECOND S
DISTANCE OF 371.02 FEET; THENCE RUN SO! UTH 07 DEGREES 15 TO THE RIGHT;
WEST A DISTANCE OF 920.40 FEET TO THE POINT OF C! URVAT URE OF A CURVE
RUN SOUTHWESTERLY ALONG THE ARC OF SAID CURVE, CONCAVE
THENCE
NORTHWESTERLY WITH A RADIUS OF 460.00 FEET.
ARC DISTANCE OF
THROUGH A CENTRAL ANGLE OF 43 DEGRI EES 22 MINUTES 22 SECONDS AN
348.22 FEET TO A POINT OF TANGENCY; THENCE RUN SOUTH 50 DEGREES 37 MINUTES 57
SOUTH 30 DEGREE S 51 MINUTES
SECONDS WEST A DISTANCE OF 284.41 FI EET. THENCE RUN
31 SECONDS WEST A DISTANCE OF 2 14.31
CE OF
FEET; THENCE RUN SOUTH 23 DEGI REES 12 MINUTES 31 SECONDS WEST A DISTAN
WEST 1/4 OF SOUTH EAST 1/4 OF
272.74 FEET TO THE NORTHEAST CORNE 8 OF THE SOUTH ALONG
39 MINUTE S 24 SECON DS EAST,
SAID SECTION 25; THENCE RUN SOUTH 02 DEGRE ES
Page 4 of 8
SPECIAL WARRANTY DEED
(Continued)
THE EAST LINE OF SAID SOUTHWEST 1/4 OF SOUTHEAST 1/4, A DISTANCE OF 515.91 FEET;
THENCE RUN SOUTH 19 DEGREES 45 MINUTES 44 SECONDS WEST A DISTANCE OF 334.48
FEET, THENCE RUN SOUTH 58 DEGREES 04 MINUTES 05 SECONDS WEST A
DISTANCE OF 295.85 FEET; THENCE RUN SOUTH 31 DEGREES 26 MINUTES 07 SECONDS WEST
A DISTANCE OF 539.26 FEET; THENCE RUN SOUTH 74 DEGREES 43 MINUTES 47 SECONDS
WEST A DISTANCE OF 247.90 FEET; THENCE RUN SOUTH 84 DEGREES 49 MINUTES 31
SECONDS WEST A DISTANCE OF 277.50 FEET; THENCE RUN NORTH 07 DEGREES 42 MINUTES
57 SECONDS EAST A DISTANCE OF 41.03 FEET; THENCE RUN NORTH 84 DEGREES 48 MINUTES
31 SECONDS EAST A DISTANCE OF 264.81 FEET; THENCE RUN NORTH 74 DEGREES 43
MINUTES 47 SECONDS EAST A DISTANCE OF 228.50 FEET; THENCE RUN NORTH 31 DEGREES
26 MINUTES 07 SECONDS EAST A DISTANCE OF 592.86 FEET; THENCE RUN NORTH 58
DEGREES 04 MINUTES 05
SECONDS EAST A DISTANCE OF 264.81 FEET; THENCE RUN NORTH 74 DEGREES 43 MINUTES
47 SECONDS EAST A DISTANCE OF 228.50 FEET; THENCE RUN NORTH 31 DEGREES 26
MINUTES 07 SECONDS EAST A
DISTANCE OF 532.86 FEET; THENCE RUN NORTH 58 DEGREES 04 MINUTES 05 SECONDS EAST
A DISTANCE OF 291.43 FEET; THENCE RUN NORTH 19 DEGREES 45 MINUTES 44 SECONDS
EAST A DISTANCE OF 312.66 FEET; THENCE RUN NORTH 02 DEGREES 39 MINUTES 24
SECONDS WEST A DISTANCE OF 517.17 FEET; THENCE RUN NORTH 23 DEGREES 12 MINUTES
31 SECONDS EAST A DISTANCE OF 284.60 FEET; THENCE RUN NORTH 30 DEGREES 51
MINUTES 31 SECONDS EAST A DISTANCE OF 223.96 FEET; THENCE RUN NORTH 50 DEGREES
37 MINUTES 57 SECONDS EAST A DISTANCE OF 291.38 FEET TO THE POINT OF CURVATURE
OF ACURVE TO THE LEFT. THENCE RUN NORTHEASTERLY ALONG THE ARC OF SAID CURVE,
CONCAVE
NORTHWESTERLY WITH A RADIUS OF 420.00 FEET, THROUGH A CENTRAL ANGLE OF 43
DEGREES 22 MINUTES 22 SECONDS AN ARC DISTANCE OF 317.94 FEET TO A POINT OF
TANGENCY; THENCE RUN NORTH 07 DEGREES 15 MINUTES 35 SECONDS EAST A DISTANCE OF
920,72 FEET; THENCE RUN NORTH 08 DEGREES 05 MINUTES 37 SECONDS EAST A DISTANCE
OF 369.73 FEET; THENCE RUN NORTH 03 DEGREES 41 MINUTES; 43 SECONDS EAST A
DISTANCE OF 351.98 FEET TO THE POINT OF CURVATURE OF A CURVE TO THE RIGHT,
THENCE RUN NORTHEASTERLY ALONG THE ARC OF SAID CURVE, CONCAVE SOUTHEASTERLY
WITH A RADIUS OF 140.00 FEET, THROUGH A CENTRAL ANGLE OF 80 DEGREES 02 MINUTES 19
SECONDS AN ARC
DISTANCE OF 195.57 FEET TO A POINT OF TANGENCY; THENCE RUN NORTH 83 DEGREES 44
MINUTES 02 SECONDS EAST A DISTANCE OF 260.83 FEET; THENCE RUN NORTH 42 DEGREES
04 MINUTES 27 SECONDS EAST A DISTANCE OF 190.92 FEET; THENCE RUN NORTH 02
DEGREES 31 MINUTES 40 SECONDS WEST A DISTANCE OF 1098.71 FEET TO APOINT ON THE.
AFORESAID SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18, SAID POINT BEING ON THE
ARC OF A CURVE FROM WHICH A RADIAL POINT BEARS SOUTH 01 DEGREE 50 MINUTES 08
SECONDS EAST; THENCE RUN EASTERLY ALONG SAID SOUTH RIGHT-OF-WAY LINE OF STATE
ROAD NO. 18, AND ALONG SAID ARC OF SAID CURVE, CONCAVE SOUTHERLY WITH A RADIUS
AN
OF 11409.2 FEET, THROUGH A CENTRAL ANGLE OF 00 DEGREES 04 MINUTES; 16 SECONDS
88
ARG DISTANCE OF 14.14 FEET TO THE POINT OF TANGENCY;, THENCE RUN NORTH
DEGREES 14; MINUTES 08 SECONDS EAST, CONTINUI NG ALONG SAID SOUTH RIGHT-OF -WAY
LINE OF STATE ROAD NO. 18, A DISTANCE OF 25.86 FEET TO THE POINT OF BEGINNING.
D IN
SUBJECT TO THAT CERTAIN DISTRIBUTION RIGHT OF WAY EASEMENT RECORDE
OFFICIAL RECORD BOOK 47 AT PAGES 326-328, PUBLIC RECORDS OF UNION COUNTY,
FLORIDA.
IIF AS TO 3/4 INTEREST IN MINERAL AND PHOSPHATE
SUBJECT TO RESERVATION O! JF TRUSTEE
DEVELOP,
AND 1/2 IN ALL OIL AND GAS BELOW THE SURF; ACE WITH RIGHT TO MINE AND
ACCORDING TO DEED
COUNTY,
RECORDED IN OFFICIAL RECORD BOOK 1, PAGE 266, PUBLIC RECORDS OF UNION
Page 5 of 8
SPECIAL WARRANTY DEED
(Continued)
FLORIDA. INCLUDING A PERPETUAL NON-EXCLUSIVE EASEMENT FOR INGRESS, EGRESS AND
PUBLIC UTILITIES BEING 20 FEET WIDE, LYING, BEING AND SITUATE IN SECTION %,
TOWNSHIP 6 SOUTH, RANGE 18 EAST, UNION COUNTY, FLORIDA, MORE PARTICULARLY
DESCRIBED AS FOLLOWS:
COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION 36; THENCE RUN NORTH 86
DEGREES 46 MINUTES 14 SECONDS EAST ALONG THE NORTH LINE OF SAID SECTION 36 FOR
A DISTANCE OF 2031.74 FEET TO THE POINT OF BEGINNING; THENCE RUN NORTH 86
DEGREES 46 MINUTES 14 SECONDS EAST A DISTANCE OF 110 FEET; THENCE RUN SOUTH 80
DEGREES 19 MINUTES 51 SECONDS EAST A DISTANCE 515.12 FEET; THENCE RUN NORTH 84
DEGREES 49 MINUTES 34 SECOND'S EAST A DISTANCE OF 78.07 FEET; THENCE RUN SOUTH
07 DEGREES 42 MINUTES 57 SECONDS WEST A DISTANCE OF 41.03 FEET; THENCE RUN
NORTH, 80 DEGREES 19 MINUTES 51 SECONDS WEST A DISTANCE OF 593.97 FEET; THENCE;
RUN SOUTH 86
DEGREES 46, MINUTES 14 SECONDS WEST A DISTANCE OF 110 FEET; THENCE RUN NORTH 03,
DEGREES 13 MINUTES 56 SECONDS WEST A DISTANCE OF 20 FEET, MORE OR LESS, TO THE
POINT OF BEGINNING. :
RESERVING UNTO THE GRANTOR, HIS HEIRS, SUCCESSORS AND ASSIGNS A PERPETUAL,
NON-EXCLUSIVE EASEMENT FOR INGRESS, EGRESS AN PUBLIC UTILITIES OVER AND ACROSS
THE NORTHERLY20 FEET OF THE WITHIN CONVEYED PROPERTY.
LOT 8:
A PARCEL OF LAND LYING: INAND BEING A PART OF SECTION 36, TOWNSHIP 6 SOUTH, RANGE
18 EAST, UNION COUNTY, FLORIDA, DESCRIBED AS FOLLOWS:
COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION, 36; THENCE NORTH 86
DEGREES 46 MINUTES 14 SECONDS EAST ALONG THE NORTH LINE OF SAID SECTION 36 FOR
A DISTANCE OF 1771.74 FEET TO THE POINT OF BEGINNING OF THE HEREIN DESCRIBED
PARCEL; THENCE CONTINUE NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST FOR A
DISTANCE OF 130.00 FEET; THENCE SOUTH 04 DEGREES; 37 MINUTES 32 SECONDS EAST FOR
ADISTANCE OF 835 FEET, MORE OR LESS TO THE THREAD OF THE SANTAFE RIVER;
THENCE MEANDER SOUTHWESTERLY ALONG SAID THREAD OF THE SANTA FE RIVER TO A
POINT WHICH BEARS SOUTH 05 DEGREES 3.0 MINUTES 14 SECONDS EAST FROM THE POINT
OF BEGINNING; THENCE
NORTH 05 DEGREES 30 MINUTES 14 SECONDS WEST FOR A DISTANCE OF 845 FEET, MORE OR
LESS; TO THE POINT OF BEGINNING; CONTAINING 2.38 ACRES, MORE OR LESS.
RESERVING UNTO THE GRANTOR HIS HEIRS, SUCCESSORS AND ASSIGNS A PERPETUAL,
NON-EXCLUSIVE EASEMENT FOR INGRESS, EGRESS AND PUBLIC UTILITIES OVER AND
ACROSS THE NORTH 20 FEET THEREOF.
TOGETHER WITH A PERPETUAL NON-EXCLUSIVE EASEMENT FOR INGRESS AND EGRESS P 6
BEING 40 FEET WIDE LYING; BEING AND SITUATE IN SECTIONS 25 AND 36, TOWNSHI
SOUTH, RANGE 18 EAST, AND IN SECTION 30, TOWNSHIP 6 SOUTH, RANGE 19 EAST, UNION
COUNTY, FLORIDA, MORE PARTICULARLY DESCRIBEDAS FOLLOWS:
COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION 30, THENCE RUN. NORTH 88
DEGREES 26 MINUTES 15 SECONDS EAST, ALONG THE NORTH LINE OF SAID SECTION 30, A
DIST, ANCE OF 116.51 FEET; THENCE RUN SOU TH 02 DEGREES 31 MINUTES 40 SECONDS EAST
A DISTANCE OF 83.6: 9 FEET TO THE SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18 AND
UE
THE POINT OF BEGINNING OF T| HE HEREINAFTER DESCRIBED EASEMENT; THENCE CONTIN
FEET;
RUNNING SOUTH 02 DEGREES 31 MINUTE: S 40 SECONDS EAST A DISTANCE OF 1114.59;
RUN, SOUTH 42 DEGREES 04 MINUTES 27 SECONDS WEST A DISTANC E OF 166.73
THENCE
Page 6 of 8
SPECIAL WARRANTY DEED
(Continued)
FEET TO THE SOUTHWEST CORNER OF THE WEST 1/2 OF NORTHWEST 1/4 OF NORTHWEST
1/4 OF SAID SECTION 30; THENCE CONTINUE RUNNING SOUTH 42 DEGREES 04 MINUTES 27
SECONDS WEST A DISTANCE OF 55.82 FEET; THENCE RUN SOUTH 83 DEGREES 44 MINUTES
02 SECONDS WEST A DISTANCE OF 276.04 FEET TO THE POINT OF CURVATURE OF A CURVE
TO THE LEFT; THENCE RUN SOUTHWESTERLY ALONG THE ARC OF SAID CURVE, CONCAVE
SOUTHEASTERLY WITH A RADIUS OF 100.00 FEET, THROUGH A CENTRAL ANGLE OF 80
DEGREES 02 MINUTES 19 SECONDS AN ARC DISTANCE OF 139.69 FEET TO A POINT OF
TANGENCY; THENCE RUN SOUTH 03 DEGREES 41 MINUTES 43 SECONDS WEST A DISTANCE
OF 353.51 FEET; THENCE RUN SOUTH 08 DEGREES 05 MINUTES 37 SECONDS WEST A
DISTANCE OF 371.02 FEET; THENCE RUN SOUTH 07 DEGREES 15 MINUTES 35 SECONDS WEST
A DISTANCE OF 920.40 FEET TO THE POINT OF CURVATURE OF A CURVE TO THE RIGHT;
THENCE RUN SOUTHWESTERLY ALONG THE ARC OF SAID CURVE, CONCAVE
NORTHWESTERLY WITH A RADIUS OF 460.00 FEET, THROUGH A CENTRAL ANGLE OF 43
DEGREES 22 MINUTES 22 SECONDS AN ARC DISTANCE OF 348.22 FEET TO A POINT OF
TANGENCY; THENCE RUN SOUTH 50 DEGREES 37 MINUTES 57 SECONDS WEST A DISTANCE
OF 284.41 FEET; THENCE RUN SOUTH 30 DEGREES. 51 MINUTES 31 SECONDS WEST A
DISTANCE OF 214.31 FEET; THENCE RUN SOUTH 23 DEGREES 12 MINUTES 31 SECONDS WEST
A DISTANCE OF 272.74 FEET TO THE NORTHEAST CORNER OF
THE SOUTHWEST 1/4 OF SOUTHEAST 1/4 OF SAID SECTION 25; THENCE RUN SOUTH 02
DEGREES 39 MINUTES 24 SECONDS EAST, ALONG THE EAST LINE OF SAID SOUTHWEST 1/4
OF SOUTHEAST 1/4, A DISTANCE OF 515.91 FEET; THENCE RUN SOUTH 19 DEGREES 45
MINUTES 44 SECONDS WEST A DISTANCE OF 334 48 FEET; THENCE RUN SOUTH 58 DEGREES
04 MINUTES 05 SECONDS WEST A DISTANCE OF 295.85 FEET; THENCE RUN SOUTH 31
DEGREES 26 MINUTES 07 SECONDS WEST A DISTANCE OF 539.26 FEET; THENCE RUN SOUTH
74 DEGREES 43 MINUTES 47 SECONDS WEST A DISTANCE OF 247.90 FEET; THENCE RUN
SOUTH 84 DEGREES 49 MINUTES 31 SECONDS WEST A DISTANCE OF 277.50 FEET, THENCE
RUN NORTH 07 DEGREES 42 MINUTES 57 SECONDS EAST A DISTANCE OF 41.03 FEET; THENCE
RUN NORTH 84 DEGREES 49 MINUTES 31 SECONDS EAST A DISTANCE OF 264.81 FEET;
THENCE RUN NORTH 74 DEGREES 43 MINUTES 47 SECONDS EAST A DISTANCE OF 228.50
FEET; THENCE RUN NORTH 31 DEGREES 26 MINUTES 07 SECONDS EAST A DISTANCE OF
532.86 FEET; THENCE RUN NORTH 58 DEGREES 04 MINUTES 05 SECONDS EAST A
DISTANCE OF 291.43 FEET; THENCE RUN NORTH 19 DEGREES 45 MINUTES 44 SECONDS EAST
A DISTANCE OF 312.66 FEET: THENCE RUN NORTH 02 DEGREES 39 MINUTES 24 SECONDS
WEST A DISTANCE OF 517.17 FEET; THENCE RUN NORTH 23 DEGREES 12 MINUTES 31
SECONDS EAST A DISTANCE OF 284.60 FEET; THENCE RUN NORTH 30 DEGREES 51 MINUTES
31 SECONDS EAST A DISTANCE OF 223.96 FEET; THENCE RUN NORTH 50 DEGREES 37
MINUTES 57 SECONDS EAST A DISTANCE OF 291.38 FEET TO THE POINT OF CURVATURE OF A
CURVE TO THE LEFT; THENCE RUN NORTHEASTERLY ALONG THE ARC OF SAID CURVE,
ANGLE
CONCAVE NORTHWESTERLY WITH A RADIUS OF 420.00 FEET, THROUGH A CENTRAL
AN ARC DISTANCE OF 317.94 FEET TOA POINT OF
OF 43 DEGREES 22 MINUTES 22 SECONDS OF
TANGENCY; THENCE RUN NORTH 07 DEGREES 15 MINUTES 35 SECONDS EAST A DISTANCE
920.72 FEET, THENCE RUN NORTH 08
RUN NORTH
DEGREES 05 MINUTES 37 SECONDS EAST A DISTANCE OF 369.73 FEET, THENCE
03 DEGREES 41 MINUTES 43 SECONDS EAST A DISTANCE OF 35198 FEET TO THE POINT OF
ALONG THE ARC OF
CURVATURE OF A CURVE TO THE RIGHT, THENCE RUN NORTHEASTERLY
SAID CURVE, CONCAVE SOUTHEA STERLY WITH A RADIUS OF 140.00 FEET, THROUGH A
OF 195.57
CENTRAL ANGLE OF 80 DEGREES 0: 2 MINUTES 19 SECONDS AN ARC DISTANCE
MINUTES 02
FEET TO APOINT OF TANGENCY, THENCE RU! IN NORTH 83 DEGREES 44
SECONDS EAST A DISTANCE OF 260.83 FEET; THENCE Ri UN NORTH
42 DEGREES 04 MINUTES
27 SECONDS EAST A DISTANCE OF 190.92 FEET: THENCE Ri UN NORTH 02 DEGREES 31
MINUTES 40 SECONDS WEST A
OF-WAY LINE OF
DISTANCE OF 1098.71 FEET TO A POINT ON THE AFORESAID SOUTH RIGHT~
FROM WHICH THE RADIAL
STATE ROAD NO. 18, SAID POINT BEING ON THE ARC OF A CURVE
Page 7 of 8
SPECIAL WARRANTY DEED
(Continued)
POINT BEARS SOUTH 01 DEGREE 50 MINUTES 08 SECONDS EAST, THENCE RUN EASTERLY
ALONG SAID SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18, AND ALONG SAID ARC OF
SAID CURVE, CONCAVE SOUTHERLY WITH A RADIUS OF 11409.2 FEET, THROUGH A CENTRAL
ANGLE OF 00 DEGREES 04 MINUTES 16 SECONDS AN ARC DISTANCE OF 14.14
FEET TO THE POINT OF TANGENCY; THENCE RUN NORTH 88 DEGREES 14 MINUTES 08
SECONDS EAST, CONTINUING ALONG SAID SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO.
18, ADISTANCE OF 25.86 FEET TO THE POINT OF BEGINNING.
SUBJECT TO THAT CERTAIN DISTRIBUTION RIGHT OF WAY EASEMENT RECORDED IN OFFICIAL
RECORD BOOK 47 AT PAGES 326-328, PUBLIC RECORDS OF UNION COUNTY, FLORIDA,
INCLUDING A PERPETUAL NONEXCLUSIVE EASEMENT FOR INGRESS EGRESS AND PUBLIC
UTILITIES BEING 20 FEET WIDE, LYING; BEING AND SITUATE IN SECTION 36, TOWNSHIP 6
SOUTH, RANGE 18 EAST, UNION COUNTY, FLORIDA MORE PARTICULARLY DESCRIBED AS
FOLLOWS:
COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION 36; THENCE RUN NORTH 86
DEGREES 46 MINUTES 14 SECONDS EAST ALONG THE NORTH LINE OF SAID SECTION 36 FOR
A DISTANCE OF 1771.74 FEET TO THE POINT OF BEGINNING; THENCE RUN NORTH 86
DEGREES 46 MINUTES 14 SECONDS EAST A DISTANCE OF 370 FEET; THENCE RUN SOUTH 80
DEGREES 19 MINUTES 51 SECONDS EAST A DISTANCE OF 515.12 FEET TO A POINT
HEREINAFTER REFERRED TO AS POINT A; THENCE RUN NORTH 84 DEGREES 49 MINUTES 31
SECONDS EAST A DISTANCE OF 78.07 FEET; THENCE RUN SOUTH 07 DEGREES 42 MINUTES 57
SECONDS WEST A DISTANCE OF 41.03 FEET; THENCE RUN NORTHWESTERLY TO A POINT 20
FEET SOUTH 07
DEGREES 42 MINUTES 57 SECONDS WEST OF POINT A THENCE RUN NORTH 80 DEGREES 19
MINUTES 51 SECONDS WEST A DISTANCE OF 515.12 FEET; THENCE RUN SOUTH 86 DEGREES
46 MINUTES 14 SECONDS WEST A DISTANCE OF 370 FEET; THENCE RUN NORTH 05 DEGREES
OF
30 MINUTES 14 SECONDS WEST A DISTANCE OF 20 FEET, MORE OR LESS TO THE POINT
BEGINNING.
Page 8 of 8
THE EIGHTH JUDICIAL CIRCUIT OF FLORIDA
ADMINISTRATIVE ORDER NO. 3.09
STANDING CASE MANAGEMENT ORDER IN COUNTY AND CIRCUIT CIVIL CASES
WHEREAS, AOSC20-23 (amendment 10) requires the chief judge of each judicial circuit
to promulgate an administrative order adopting a formal case management protocol for civil
cases; and
WHEREAS, AOSC20-23 (amendment 10) requires the Chief Judge to cause a case
management order establishing certain deadlines to be served in every civil case, it is hereby
ORDERED:
1. The presiding judge in each civil case shall actively manage all civil cases and shall
strictly comply with Florida Rule of Judicial Administration 2.545(a), (b) and {e).
2. This order does not apply to cases proceeding under the Smali Claims Rules; to
landlord/tenant actions; to actions for unlawful detainer; or to any action requiring summary
procedure pursuant to section 51.011, Florida Statutes.
3 A system of differentiated case management shall be utilized in civil cases, which
requires designation of each case as one of the following: complex, streamlined, or general.
4. Complex civil cases shall be so designated pursuant to the criteria in Florida Rule
of Civil Procedure 1.201, Upon such designation, complex civil cases shall proceed as stated in
that rule.
5. Factors to be considered by the trial judge in designating a case as streamlined
shall include, but are not limited to, cases in which:
(a) There are no more than two parties;
(b) issues of liability and damages are not complex;
(c) Relatively few pretrial motions are anticipated;
(d) The need for discovery is limited;
(e) There are relatively few witnesses anticipated;
(f) Documentary evidence is anticipated to be minimal;
(g) The trial is anticipated to take no longer than two (2) days; or
(b) the case is otherwise likely to resolve in less than twelve months.
we een ene —
el
Standing Case Management Order in Civil Cases Effective: April 30, 2021
6. Any case not specifically designated as complex or streamlined shall be
categorized as general.
7. in each civil case, the standing civil case management order (attached hereto as
Appendix A) shall be signed by the plaintiff and filed in the court file along with the complaint.
The plaintiff shall cause the standing order to be served, along with the complaint, on each
named defendant. The Clerk shall not accept a civil case for filing without submission of the
signed standing order.
8 Deadlines established herein shall be strictly enforced. This order may be
modified when the case is at issue by further order of the court.
ORDERED ON this 23 day of April 2021.
Wass eT a
Mark W. Moseley, Chief Judge
AQ 3.09 Page 2.
Standing Case Management Order in Civil Cases Effective: April 30, 2024
IN THE EIGHTH JUDICIAL CIRCUIT OF FLORIDA
STANDING CASE MANAGEMENT ORDER
{AOSC20-23]
THIS ACTION is before the court for case management pursuant to AOQSC20-23
{Amendment 10). Therefore, it is ADJUDGED that:
1. This case is provisionally designated as a general civil case.
2. TRIAL DATE: The projected date for a non-jury trial shall be the first regular trial
term taking place one year after the date of filing. The projected date for a jury trial shall be the
first regular trial term taking place eighteen months after the date of filing. A firm trial date will
be established by the presiding judge when the case is at issue. Trial term dates for each civil
division are published on the Eighth Judicial Circuit Court website at httos://circuit8.org/court-
calendars/master-calendars/. In county court cases, any case redesignated by the trial court as
a streamlined case, in cases where the parties request it, or in any other case the trial court
deems it appropriate, the trial date may be adjusted to take piace sooner. Judges shall apply a
firm continuance policy allowing continuances only for good cause shown.
3. SERVICE: Unless otherwise extended by court order for good cause shown, service of
complaints should be completed within 120 days of filing. Requests for the addition of new
parties shall be filed within 180 days of filing.
4, DISCOVERY: Fact and expert discovery shall be completed 60 days prior to the trial
date set forth above.
5. PRETRIAL MOTIONS: Objections to pleadings and pretrial motions shall be resolved a
minimum of 30 days prior to the trial date set forth above. Prior to filing ANY motion, counsel
AO 3.09 Page Adi
Standing Case Management Order Effective: April 30, 2021
filing the motion shall confer with opposing counsel by telephone or in person in a good faith
attempt to resolve the motion. The motion shall contain a good faith statement reflecting the
date and time of the conference with opposing counsel. A statement that counsel attempted to
confer with opposing counsel is insufficient unless the good faith statement details the date
and time of at least three attempts to confer that occurred within the one-month period
immediately prior to the filing of the motion,
6. MEDIATION: The parties shall conclude mediation at least 90 days prior to the trial
date set forth above.
7. Deadlines established herein shall be strictly enforced. “Lawyers must strictly comply
with Florida Rule of General Practice and Judicial Administration 2.545(a), which requires
lawyers to conclude litigation as soon as it is reasonably and justly possible to do so, and the
pandemic alone is not a basis for a lawyer’s failure to prepare a case for trial or otherwise
actively manage a case.” This order may be modified at such time that the case is determined
to be at issue. Fla. R. Civ. P. 1.440.
ORDERED in Alachua County, Florida, on April 23, 2021.
a
Ve I peed
Mark W. Moseley, Chief Judge
on behalf of all presiding Eighth Circuit civil judges
| HEREBY CERTIFY that | have read and will comply with the foregoing standing order and shall
cause it to be filed and served, contemporaneously with the complaint, on all named
it
Bb
defendants.
ki GMa
Plaintiff or Plaintiff's Counsel Date
AO 3.09 Page Adi
Standing Case Management Order Effective: Apri! 30, 2021
Preview
Filing # 157780593 E-Filed 09/20/2022 02:26:55 PM IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT, IN AND FOR UNION COUNTY, FLORIDA case No.: 3-AOAD-CA-OOSS MARK A. LINK AND JOHN C. HAHN, PLAINTIFF(S), Vs. MICHAEL W. BANGERT, DEFENDANT(S) VERIFIED COMPLAINT FOR PARTITION COMES NOW the Plaintiffs, MARK A. LINK and JOHN C. HAHN, by and through their undersigned counsel, and hereby file this Verified Complaint for Partition against the Defendant, MICHAEL W. BANGERT and allege as follows: 4 This is an action for partition of real property that exceeds the sum of $30,000.00 in value. 2. This Court has jurisdiction pursuant to §64.011, Fla. Stat., and venue is proper in Union County, Florida, where the real property is situated. 3. The real property (“Property”) that is the subject of this action is located in Union County, Florida, and is more particularly described as follows: 3701 SW 94th Place, Lake Butler, FL 32054: Parcel No.:36-06-18-52-000-0070-0: Exhibit “A” attached hereto and made a part hereof by reference. Title to the Property is owned as follows: Owner Ownership Interest* MARK A. LINK and JOHN C. HAHN 2/3 MICHAEL W. BANGERT 113 Electronically Filed Union Case # 22000055CAD KM 09/20/2022 02:26:55 PM 5. MARK A. LINK, JOHN C. HAHN, and MICHAEL W. BANGERT jointly own the Property as tenants in common as evidenced by the Speciall Warranty Deed attached hereto as Exhibit “A”. 6. MARK A. LINK and JOHN C. HAHN currently reside at 3754 SW 99th Place, Lake Butler, FL 32054 and 110 S. Shore Lane, Crescent City, FL 32112, respectively. 7. To the best knowledge of the Plaintiffs, MICHAEL W. BANGERT currently resides at 3701 SW 94th Place, Lake Butler, FL 32054. 8. Plaintiffs request that this Court partition the Property in accordance with the foregoing ownership interest. 9. In the event the Court determines that the Property is non-di ible, Plaintiffs request that the Property be sold by private sale and that the proceeds therefrom be split between the parties pursuant to the respective ownership interest and applicable equitable adjustments. 10. Plaintiffs have incurred other expenses in connection with the preservation and maintenance of the Property and therefore Plaintiffs request an accounting so that special equities are considered in allocating the division of the Property or the proceeds therefrom. 11. Plaintiffs have retained the undersigned firm Curtis Law Firm, LLC, and have agreed to pay a reasonable fee for their services. 12. Pursuant to §64.081 Fla. Stat., Plaintiffs are entitled to their reasonable attorney’s fees and costs incurred in this action. WHEREFORE, Plaintiffs MARK A. LINK and JOHN C. HAHN respectfully request this Court enter an order: A Requiring the Property be partitioned or if the Court determines it is not divisible that the Property be sold via private sale; B Appointing a magistrate or other qualified neutral party to conduct the sale of the Property if required; Cc Allocating the Property or proceeds of sale in proportion to the parties’ respective interests, subject to special equities that may be shown; D. Awarding Plaintiffs their reasonable attomey’s fees and costs; E Awarding Plaintiffs any further relief deemed appropriate and just. Page 2 of 8 Respectfully submitted this 20th day of September 2022. CURTIS LAW FIRM, LLC /s/ Ryan C. Curtis, Esq. Ryan C. Curtis, Esquire Florida Bar Number 0163589 175 N.W. 138" Terr., Suite 100 Jonesville, Florida 32669 (352) 333-7207 (352) 331-0818 (facsimile) Service: rcurtis@curtisiawfirm.net Attorney for Plaintiffs COMPLAINT VERIFICATION Under penalty of perjury, | declare that | have read the foregoing, and the facts alleged therein are true and correct to the best of my knowledge and belief. Oe JOHN C. HAHN WARKHA. LINK (LECP Ze Q-1G- 22 ‘Date Daie Page 3 of 8 SPECIAL WARRANTY DEED EXHIBIT A LOT 7: APARCEL OF LAND LYING IN AND BEING A PART OF SECTION 36; TOWNSHIP 6 SOUTH, RANGE 18 EAST, UNION COUNTY, FLORIDA, DESCRIBEDAS FOLLOWS: COMMENCE AT THE NORTHWEST CORNER, OF SAID SECTION 36; THENCE NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST ALONG THE NORTH LINE OF SAID SECTION 36 FOR A DISTANCE OF 1901.74 FEET TO THE POINT OF BEGINNING OF THE HEREIN DESCRIBED PARCEL; THENCE CONTINUE NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST FOR A DISTANCE OF 130.00 FEET; THENCE SOUTH 03 DEGREES, 13 MINUTES 56 SECONDS EAST FOR ADISTANCE OF 775 FEET TO THE THREAD OF THE SANTAFE RIVER; THENCE MEANDER SOUTHWESTERLY ALONG SAID THREAD OF THE SANTA FE RIVER TO A POINT WHICH BEARS SOUTH 04 DEGREES 37 MINUTES 32 SECONDS EAST FROM THE POINT OF BEGINNING THENCE NORTH 04 DEGREES 37 MINUTES 32 SECONDS WEST FOR A DISTANCE OF 835 FEET, MORE OR LESS, TO THE POINT OF BEGINNING. CONTAINING 2.22 ACRES, MORE OR LESS. SUBJECT TO AN EASEMENT FOR ROAD PURPOSE’S ACROSS THE NORTH 20 FEET THEREOF. TOGETHER, WITH A PERPETUAL NONEXCLUSIVE EASEMENT FOR INGRESS AND EGRESS BEING 40 FEET WIDE LYING, BEIN' IG AND SITUATE IN SECTIONS 25 AND 36, TOWNSHIP 6 SOUTH, RANGE 18 EAST, AND IN SECTION 30, TOWNSHIP 6 SOUTH, RANGE 19 EAST, UNION COUNTY, FLORIDA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION 30, THENCE RUN NORTH 88A DEGREES 26 MINUTES 15 SECONDS EAST, ALONG THE NORTH LINE OF SAID SECTION 30, DISTANCE OF 116.51 FEET; THENCE RUN SOUTH 02 DEGREES 31 MINUTES 40 SECONDS EAST AND A DISTANCE OF 83.69 FEET TO THE SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18 OF BEGINNIN G OF THE HEREINAF TER DESCRIBE D EASEMEN T; THENCE CONTINUE THE POINT RUNNING SOUTH 02 DEGREES 31 MINUTES 40 SECONDS EAST A DISTANCE, OF 1114.59 FEET; THENCE RUN SOUTH 42 DEGREES 04 MINUTES 27 SECONDS WEST A DISTANCE OF 166.73 FEET TO THE SOUTHWEST CORNER OF THE WEST 1/2 OF NORTHWEST 1/4 OF NORTHWEST 1/4 OF SAID SECTION 30; THENCE CONTINUE RUNNING SOUTH 42 DEGREES 04 MINUTES 27 SECONDS WEST A DISTANCE, OF 55.82 FEET; THENCE RUN SOUTH 83 DEGREES 44 MINUTES 02 SECONDS WEST A DISTANCE OF 276.04 FEET TO THE POINT OF CURVATURE OF A CURVE CONCAVE TO THE LEFT; THENCE RUN SOUTHWESTERLY ALONG THE ARC OF SAID CURVE, ANGLE OF 80 SOUTHEASTERLY WITH A RADIUS OF 100.00 FEET, THROUGH A CENTRAL E OF 139.69 FEET TO A POINT OF DEGR' fES 02 MINUTES 19 SECONDS AN ARC DISTANC TANGENCY, THENC! RUN SOUTH 03 DEGREE S 41 MINUTES 43 SECOND S WEST A DISTANCE OF 353.51 FEET, THENCE RUN S' OUTH 08 DEGREE S 05 MINUTE S 37 SECOND S WEST A MINUTE S; 35 SECOND S DISTANCE OF 371.02 FEET; THENCE RUN SO! UTH 07 DEGREES 15 TO THE RIGHT; WEST A DISTANCE OF 920.40 FEET TO THE POINT OF C! URVAT URE OF A CURVE RUN SOUTHWESTERLY ALONG THE ARC OF SAID CURVE, CONCAVE THENCE NORTHWESTERLY WITH A RADIUS OF 460.00 FEET. ARC DISTANCE OF THROUGH A CENTRAL ANGLE OF 43 DEGRI EES 22 MINUTES 22 SECONDS AN 348.22 FEET TO A POINT OF TANGENCY; THENCE RUN SOUTH 50 DEGREES 37 MINUTES 57 SOUTH 30 DEGREE S 51 MINUTES SECONDS WEST A DISTANCE OF 284.41 FI EET. THENCE RUN 31 SECONDS WEST A DISTANCE OF 2 14.31 CE OF FEET; THENCE RUN SOUTH 23 DEGI REES 12 MINUTES 31 SECONDS WEST A DISTAN WEST 1/4 OF SOUTH EAST 1/4 OF 272.74 FEET TO THE NORTHEAST CORNE 8 OF THE SOUTH ALONG 39 MINUTE S 24 SECON DS EAST, SAID SECTION 25; THENCE RUN SOUTH 02 DEGRE ES Page 4 of 8 SPECIAL WARRANTY DEED (Continued) THE EAST LINE OF SAID SOUTHWEST 1/4 OF SOUTHEAST 1/4, A DISTANCE OF 515.91 FEET; THENCE RUN SOUTH 19 DEGREES 45 MINUTES 44 SECONDS WEST A DISTANCE OF 334.48 FEET, THENCE RUN SOUTH 58 DEGREES 04 MINUTES 05 SECONDS WEST A DISTANCE OF 295.85 FEET; THENCE RUN SOUTH 31 DEGREES 26 MINUTES 07 SECONDS WEST A DISTANCE OF 539.26 FEET; THENCE RUN SOUTH 74 DEGREES 43 MINUTES 47 SECONDS WEST A DISTANCE OF 247.90 FEET; THENCE RUN SOUTH 84 DEGREES 49 MINUTES 31 SECONDS WEST A DISTANCE OF 277.50 FEET; THENCE RUN NORTH 07 DEGREES 42 MINUTES 57 SECONDS EAST A DISTANCE OF 41.03 FEET; THENCE RUN NORTH 84 DEGREES 48 MINUTES 31 SECONDS EAST A DISTANCE OF 264.81 FEET; THENCE RUN NORTH 74 DEGREES 43 MINUTES 47 SECONDS EAST A DISTANCE OF 228.50 FEET; THENCE RUN NORTH 31 DEGREES 26 MINUTES 07 SECONDS EAST A DISTANCE OF 592.86 FEET; THENCE RUN NORTH 58 DEGREES 04 MINUTES 05 SECONDS EAST A DISTANCE OF 264.81 FEET; THENCE RUN NORTH 74 DEGREES 43 MINUTES 47 SECONDS EAST A DISTANCE OF 228.50 FEET; THENCE RUN NORTH 31 DEGREES 26 MINUTES 07 SECONDS EAST A DISTANCE OF 532.86 FEET; THENCE RUN NORTH 58 DEGREES 04 MINUTES 05 SECONDS EAST A DISTANCE OF 291.43 FEET; THENCE RUN NORTH 19 DEGREES 45 MINUTES 44 SECONDS EAST A DISTANCE OF 312.66 FEET; THENCE RUN NORTH 02 DEGREES 39 MINUTES 24 SECONDS WEST A DISTANCE OF 517.17 FEET; THENCE RUN NORTH 23 DEGREES 12 MINUTES 31 SECONDS EAST A DISTANCE OF 284.60 FEET; THENCE RUN NORTH 30 DEGREES 51 MINUTES 31 SECONDS EAST A DISTANCE OF 223.96 FEET; THENCE RUN NORTH 50 DEGREES 37 MINUTES 57 SECONDS EAST A DISTANCE OF 291.38 FEET TO THE POINT OF CURVATURE OF ACURVE TO THE LEFT. THENCE RUN NORTHEASTERLY ALONG THE ARC OF SAID CURVE, CONCAVE NORTHWESTERLY WITH A RADIUS OF 420.00 FEET, THROUGH A CENTRAL ANGLE OF 43 DEGREES 22 MINUTES 22 SECONDS AN ARC DISTANCE OF 317.94 FEET TO A POINT OF TANGENCY; THENCE RUN NORTH 07 DEGREES 15 MINUTES 35 SECONDS EAST A DISTANCE OF 920,72 FEET; THENCE RUN NORTH 08 DEGREES 05 MINUTES 37 SECONDS EAST A DISTANCE OF 369.73 FEET; THENCE RUN NORTH 03 DEGREES 41 MINUTES; 43 SECONDS EAST A DISTANCE OF 351.98 FEET TO THE POINT OF CURVATURE OF A CURVE TO THE RIGHT, THENCE RUN NORTHEASTERLY ALONG THE ARC OF SAID CURVE, CONCAVE SOUTHEASTERLY WITH A RADIUS OF 140.00 FEET, THROUGH A CENTRAL ANGLE OF 80 DEGREES 02 MINUTES 19 SECONDS AN ARC DISTANCE OF 195.57 FEET TO A POINT OF TANGENCY; THENCE RUN NORTH 83 DEGREES 44 MINUTES 02 SECONDS EAST A DISTANCE OF 260.83 FEET; THENCE RUN NORTH 42 DEGREES 04 MINUTES 27 SECONDS EAST A DISTANCE OF 190.92 FEET; THENCE RUN NORTH 02 DEGREES 31 MINUTES 40 SECONDS WEST A DISTANCE OF 1098.71 FEET TO APOINT ON THE. AFORESAID SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18, SAID POINT BEING ON THE ARC OF A CURVE FROM WHICH A RADIAL POINT BEARS SOUTH 01 DEGREE 50 MINUTES 08 SECONDS EAST; THENCE RUN EASTERLY ALONG SAID SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18, AND ALONG SAID ARC OF SAID CURVE, CONCAVE SOUTHERLY WITH A RADIUS AN OF 11409.2 FEET, THROUGH A CENTRAL ANGLE OF 00 DEGREES 04 MINUTES; 16 SECONDS 88 ARG DISTANCE OF 14.14 FEET TO THE POINT OF TANGENCY;, THENCE RUN NORTH DEGREES 14; MINUTES 08 SECONDS EAST, CONTINUI NG ALONG SAID SOUTH RIGHT-OF -WAY LINE OF STATE ROAD NO. 18, A DISTANCE OF 25.86 FEET TO THE POINT OF BEGINNING. D IN SUBJECT TO THAT CERTAIN DISTRIBUTION RIGHT OF WAY EASEMENT RECORDE OFFICIAL RECORD BOOK 47 AT PAGES 326-328, PUBLIC RECORDS OF UNION COUNTY, FLORIDA. IIF AS TO 3/4 INTEREST IN MINERAL AND PHOSPHATE SUBJECT TO RESERVATION O! JF TRUSTEE DEVELOP, AND 1/2 IN ALL OIL AND GAS BELOW THE SURF; ACE WITH RIGHT TO MINE AND ACCORDING TO DEED COUNTY, RECORDED IN OFFICIAL RECORD BOOK 1, PAGE 266, PUBLIC RECORDS OF UNION Page 5 of 8 SPECIAL WARRANTY DEED (Continued) FLORIDA. INCLUDING A PERPETUAL NON-EXCLUSIVE EASEMENT FOR INGRESS, EGRESS AND PUBLIC UTILITIES BEING 20 FEET WIDE, LYING, BEING AND SITUATE IN SECTION %, TOWNSHIP 6 SOUTH, RANGE 18 EAST, UNION COUNTY, FLORIDA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION 36; THENCE RUN NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST ALONG THE NORTH LINE OF SAID SECTION 36 FOR A DISTANCE OF 2031.74 FEET TO THE POINT OF BEGINNING; THENCE RUN NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST A DISTANCE OF 110 FEET; THENCE RUN SOUTH 80 DEGREES 19 MINUTES 51 SECONDS EAST A DISTANCE 515.12 FEET; THENCE RUN NORTH 84 DEGREES 49 MINUTES 34 SECOND'S EAST A DISTANCE OF 78.07 FEET; THENCE RUN SOUTH 07 DEGREES 42 MINUTES 57 SECONDS WEST A DISTANCE OF 41.03 FEET; THENCE RUN NORTH, 80 DEGREES 19 MINUTES 51 SECONDS WEST A DISTANCE OF 593.97 FEET; THENCE; RUN SOUTH 86 DEGREES 46, MINUTES 14 SECONDS WEST A DISTANCE OF 110 FEET; THENCE RUN NORTH 03, DEGREES 13 MINUTES 56 SECONDS WEST A DISTANCE OF 20 FEET, MORE OR LESS, TO THE POINT OF BEGINNING. : RESERVING UNTO THE GRANTOR, HIS HEIRS, SUCCESSORS AND ASSIGNS A PERPETUAL, NON-EXCLUSIVE EASEMENT FOR INGRESS, EGRESS AN PUBLIC UTILITIES OVER AND ACROSS THE NORTHERLY20 FEET OF THE WITHIN CONVEYED PROPERTY. LOT 8: A PARCEL OF LAND LYING: INAND BEING A PART OF SECTION 36, TOWNSHIP 6 SOUTH, RANGE 18 EAST, UNION COUNTY, FLORIDA, DESCRIBED AS FOLLOWS: COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION, 36; THENCE NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST ALONG THE NORTH LINE OF SAID SECTION 36 FOR A DISTANCE OF 1771.74 FEET TO THE POINT OF BEGINNING OF THE HEREIN DESCRIBED PARCEL; THENCE CONTINUE NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST FOR A DISTANCE OF 130.00 FEET; THENCE SOUTH 04 DEGREES; 37 MINUTES 32 SECONDS EAST FOR ADISTANCE OF 835 FEET, MORE OR LESS TO THE THREAD OF THE SANTAFE RIVER; THENCE MEANDER SOUTHWESTERLY ALONG SAID THREAD OF THE SANTA FE RIVER TO A POINT WHICH BEARS SOUTH 05 DEGREES 3.0 MINUTES 14 SECONDS EAST FROM THE POINT OF BEGINNING; THENCE NORTH 05 DEGREES 30 MINUTES 14 SECONDS WEST FOR A DISTANCE OF 845 FEET, MORE OR LESS; TO THE POINT OF BEGINNING; CONTAINING 2.38 ACRES, MORE OR LESS. RESERVING UNTO THE GRANTOR HIS HEIRS, SUCCESSORS AND ASSIGNS A PERPETUAL, NON-EXCLUSIVE EASEMENT FOR INGRESS, EGRESS AND PUBLIC UTILITIES OVER AND ACROSS THE NORTH 20 FEET THEREOF. TOGETHER WITH A PERPETUAL NON-EXCLUSIVE EASEMENT FOR INGRESS AND EGRESS P 6 BEING 40 FEET WIDE LYING; BEING AND SITUATE IN SECTIONS 25 AND 36, TOWNSHI SOUTH, RANGE 18 EAST, AND IN SECTION 30, TOWNSHIP 6 SOUTH, RANGE 19 EAST, UNION COUNTY, FLORIDA, MORE PARTICULARLY DESCRIBEDAS FOLLOWS: COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION 30, THENCE RUN. NORTH 88 DEGREES 26 MINUTES 15 SECONDS EAST, ALONG THE NORTH LINE OF SAID SECTION 30, A DIST, ANCE OF 116.51 FEET; THENCE RUN SOU TH 02 DEGREES 31 MINUTES 40 SECONDS EAST A DISTANCE OF 83.6: 9 FEET TO THE SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18 AND UE THE POINT OF BEGINNING OF T| HE HEREINAFTER DESCRIBED EASEMENT; THENCE CONTIN FEET; RUNNING SOUTH 02 DEGREES 31 MINUTE: S 40 SECONDS EAST A DISTANCE OF 1114.59; RUN, SOUTH 42 DEGREES 04 MINUTES 27 SECONDS WEST A DISTANC E OF 166.73 THENCE Page 6 of 8 SPECIAL WARRANTY DEED (Continued) FEET TO THE SOUTHWEST CORNER OF THE WEST 1/2 OF NORTHWEST 1/4 OF NORTHWEST 1/4 OF SAID SECTION 30; THENCE CONTINUE RUNNING SOUTH 42 DEGREES 04 MINUTES 27 SECONDS WEST A DISTANCE OF 55.82 FEET; THENCE RUN SOUTH 83 DEGREES 44 MINUTES 02 SECONDS WEST A DISTANCE OF 276.04 FEET TO THE POINT OF CURVATURE OF A CURVE TO THE LEFT; THENCE RUN SOUTHWESTERLY ALONG THE ARC OF SAID CURVE, CONCAVE SOUTHEASTERLY WITH A RADIUS OF 100.00 FEET, THROUGH A CENTRAL ANGLE OF 80 DEGREES 02 MINUTES 19 SECONDS AN ARC DISTANCE OF 139.69 FEET TO A POINT OF TANGENCY; THENCE RUN SOUTH 03 DEGREES 41 MINUTES 43 SECONDS WEST A DISTANCE OF 353.51 FEET; THENCE RUN SOUTH 08 DEGREES 05 MINUTES 37 SECONDS WEST A DISTANCE OF 371.02 FEET; THENCE RUN SOUTH 07 DEGREES 15 MINUTES 35 SECONDS WEST A DISTANCE OF 920.40 FEET TO THE POINT OF CURVATURE OF A CURVE TO THE RIGHT; THENCE RUN SOUTHWESTERLY ALONG THE ARC OF SAID CURVE, CONCAVE NORTHWESTERLY WITH A RADIUS OF 460.00 FEET, THROUGH A CENTRAL ANGLE OF 43 DEGREES 22 MINUTES 22 SECONDS AN ARC DISTANCE OF 348.22 FEET TO A POINT OF TANGENCY; THENCE RUN SOUTH 50 DEGREES 37 MINUTES 57 SECONDS WEST A DISTANCE OF 284.41 FEET; THENCE RUN SOUTH 30 DEGREES. 51 MINUTES 31 SECONDS WEST A DISTANCE OF 214.31 FEET; THENCE RUN SOUTH 23 DEGREES 12 MINUTES 31 SECONDS WEST A DISTANCE OF 272.74 FEET TO THE NORTHEAST CORNER OF THE SOUTHWEST 1/4 OF SOUTHEAST 1/4 OF SAID SECTION 25; THENCE RUN SOUTH 02 DEGREES 39 MINUTES 24 SECONDS EAST, ALONG THE EAST LINE OF SAID SOUTHWEST 1/4 OF SOUTHEAST 1/4, A DISTANCE OF 515.91 FEET; THENCE RUN SOUTH 19 DEGREES 45 MINUTES 44 SECONDS WEST A DISTANCE OF 334 48 FEET; THENCE RUN SOUTH 58 DEGREES 04 MINUTES 05 SECONDS WEST A DISTANCE OF 295.85 FEET; THENCE RUN SOUTH 31 DEGREES 26 MINUTES 07 SECONDS WEST A DISTANCE OF 539.26 FEET; THENCE RUN SOUTH 74 DEGREES 43 MINUTES 47 SECONDS WEST A DISTANCE OF 247.90 FEET; THENCE RUN SOUTH 84 DEGREES 49 MINUTES 31 SECONDS WEST A DISTANCE OF 277.50 FEET, THENCE RUN NORTH 07 DEGREES 42 MINUTES 57 SECONDS EAST A DISTANCE OF 41.03 FEET; THENCE RUN NORTH 84 DEGREES 49 MINUTES 31 SECONDS EAST A DISTANCE OF 264.81 FEET; THENCE RUN NORTH 74 DEGREES 43 MINUTES 47 SECONDS EAST A DISTANCE OF 228.50 FEET; THENCE RUN NORTH 31 DEGREES 26 MINUTES 07 SECONDS EAST A DISTANCE OF 532.86 FEET; THENCE RUN NORTH 58 DEGREES 04 MINUTES 05 SECONDS EAST A DISTANCE OF 291.43 FEET; THENCE RUN NORTH 19 DEGREES 45 MINUTES 44 SECONDS EAST A DISTANCE OF 312.66 FEET: THENCE RUN NORTH 02 DEGREES 39 MINUTES 24 SECONDS WEST A DISTANCE OF 517.17 FEET; THENCE RUN NORTH 23 DEGREES 12 MINUTES 31 SECONDS EAST A DISTANCE OF 284.60 FEET; THENCE RUN NORTH 30 DEGREES 51 MINUTES 31 SECONDS EAST A DISTANCE OF 223.96 FEET; THENCE RUN NORTH 50 DEGREES 37 MINUTES 57 SECONDS EAST A DISTANCE OF 291.38 FEET TO THE POINT OF CURVATURE OF A CURVE TO THE LEFT; THENCE RUN NORTHEASTERLY ALONG THE ARC OF SAID CURVE, ANGLE CONCAVE NORTHWESTERLY WITH A RADIUS OF 420.00 FEET, THROUGH A CENTRAL AN ARC DISTANCE OF 317.94 FEET TOA POINT OF OF 43 DEGREES 22 MINUTES 22 SECONDS OF TANGENCY; THENCE RUN NORTH 07 DEGREES 15 MINUTES 35 SECONDS EAST A DISTANCE 920.72 FEET, THENCE RUN NORTH 08 RUN NORTH DEGREES 05 MINUTES 37 SECONDS EAST A DISTANCE OF 369.73 FEET, THENCE 03 DEGREES 41 MINUTES 43 SECONDS EAST A DISTANCE OF 35198 FEET TO THE POINT OF ALONG THE ARC OF CURVATURE OF A CURVE TO THE RIGHT, THENCE RUN NORTHEASTERLY SAID CURVE, CONCAVE SOUTHEA STERLY WITH A RADIUS OF 140.00 FEET, THROUGH A OF 195.57 CENTRAL ANGLE OF 80 DEGREES 0: 2 MINUTES 19 SECONDS AN ARC DISTANCE MINUTES 02 FEET TO APOINT OF TANGENCY, THENCE RU! IN NORTH 83 DEGREES 44 SECONDS EAST A DISTANCE OF 260.83 FEET; THENCE Ri UN NORTH 42 DEGREES 04 MINUTES 27 SECONDS EAST A DISTANCE OF 190.92 FEET: THENCE Ri UN NORTH 02 DEGREES 31 MINUTES 40 SECONDS WEST A OF-WAY LINE OF DISTANCE OF 1098.71 FEET TO A POINT ON THE AFORESAID SOUTH RIGHT~ FROM WHICH THE RADIAL STATE ROAD NO. 18, SAID POINT BEING ON THE ARC OF A CURVE Page 7 of 8 SPECIAL WARRANTY DEED (Continued) POINT BEARS SOUTH 01 DEGREE 50 MINUTES 08 SECONDS EAST, THENCE RUN EASTERLY ALONG SAID SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18, AND ALONG SAID ARC OF SAID CURVE, CONCAVE SOUTHERLY WITH A RADIUS OF 11409.2 FEET, THROUGH A CENTRAL ANGLE OF 00 DEGREES 04 MINUTES 16 SECONDS AN ARC DISTANCE OF 14.14 FEET TO THE POINT OF TANGENCY; THENCE RUN NORTH 88 DEGREES 14 MINUTES 08 SECONDS EAST, CONTINUING ALONG SAID SOUTH RIGHT-OF-WAY LINE OF STATE ROAD NO. 18, ADISTANCE OF 25.86 FEET TO THE POINT OF BEGINNING. SUBJECT TO THAT CERTAIN DISTRIBUTION RIGHT OF WAY EASEMENT RECORDED IN OFFICIAL RECORD BOOK 47 AT PAGES 326-328, PUBLIC RECORDS OF UNION COUNTY, FLORIDA, INCLUDING A PERPETUAL NONEXCLUSIVE EASEMENT FOR INGRESS EGRESS AND PUBLIC UTILITIES BEING 20 FEET WIDE, LYING; BEING AND SITUATE IN SECTION 36, TOWNSHIP 6 SOUTH, RANGE 18 EAST, UNION COUNTY, FLORIDA MORE PARTICULARLY DESCRIBED AS FOLLOWS: COMMENCE AT THE NORTHWEST CORNER OF SAID SECTION 36; THENCE RUN NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST ALONG THE NORTH LINE OF SAID SECTION 36 FOR A DISTANCE OF 1771.74 FEET TO THE POINT OF BEGINNING; THENCE RUN NORTH 86 DEGREES 46 MINUTES 14 SECONDS EAST A DISTANCE OF 370 FEET; THENCE RUN SOUTH 80 DEGREES 19 MINUTES 51 SECONDS EAST A DISTANCE OF 515.12 FEET TO A POINT HEREINAFTER REFERRED TO AS POINT A; THENCE RUN NORTH 84 DEGREES 49 MINUTES 31 SECONDS EAST A DISTANCE OF 78.07 FEET; THENCE RUN SOUTH 07 DEGREES 42 MINUTES 57 SECONDS WEST A DISTANCE OF 41.03 FEET; THENCE RUN NORTHWESTERLY TO A POINT 20 FEET SOUTH 07 DEGREES 42 MINUTES 57 SECONDS WEST OF POINT A THENCE RUN NORTH 80 DEGREES 19 MINUTES 51 SECONDS WEST A DISTANCE OF 515.12 FEET; THENCE RUN SOUTH 86 DEGREES 46 MINUTES 14 SECONDS WEST A DISTANCE OF 370 FEET; THENCE RUN NORTH 05 DEGREES OF 30 MINUTES 14 SECONDS WEST A DISTANCE OF 20 FEET, MORE OR LESS TO THE POINT BEGINNING. Page 8 of 8 THE EIGHTH JUDICIAL CIRCUIT OF FLORIDA ADMINISTRATIVE ORDER NO. 3.09 STANDING CASE MANAGEMENT ORDER IN COUNTY AND CIRCUIT CIVIL CASES WHEREAS, AOSC20-23 (amendment 10) requires the chief judge of each judicial circuit to promulgate an administrative order adopting a formal case management protocol for civil cases; and WHEREAS, AOSC20-23 (amendment 10) requires the Chief Judge to cause a case management order establishing certain deadlines to be served in every civil case, it is hereby ORDERED: 1. The presiding judge in each civil case shall actively manage all civil cases and shall strictly comply with Florida Rule of Judicial Administration 2.545(a), (b) and {e). 2. This order does not apply to cases proceeding under the Smali Claims Rules; to landlord/tenant actions; to actions for unlawful detainer; or to any action requiring summary procedure pursuant to section 51.011, Florida Statutes. 3 A system of differentiated case management shall be utilized in civil cases, which requires designation of each case as one of the following: complex, streamlined, or general. 4. Complex civil cases shall be so designated pursuant to the criteria in Florida Rule of Civil Procedure 1.201, Upon such designation, complex civil cases shall proceed as stated in that rule. 5. Factors to be considered by the trial judge in designating a case as streamlined shall include, but are not limited to, cases in which: (a) There are no more than two parties; (b) issues of liability and damages are not complex; (c) Relatively few pretrial motions are anticipated; (d) The need for discovery is limited; (e) There are relatively few witnesses anticipated; (f) Documentary evidence is anticipated to be minimal; (g) The trial is anticipated to take no longer than two (2) days; or (b) the case is otherwise likely to resolve in less than twelve months. we een ene — el Standing Case Management Order in Civil Cases Effective: April 30, 2021 6. Any case not specifically designated as complex or streamlined shall be categorized as general. 7. in each civil case, the standing civil case management order (attached hereto as Appendix A) shall be signed by the plaintiff and filed in the court file along with the complaint. The plaintiff shall cause the standing order to be served, along with the complaint, on each named defendant. The Clerk shall not accept a civil case for filing without submission of the signed standing order. 8 Deadlines established herein shall be strictly enforced. This order may be modified when the case is at issue by further order of the court. ORDERED ON this 23 day of April 2021. Wass eT a Mark W. Moseley, Chief Judge AQ 3.09 Page 2. Standing Case Management Order in Civil Cases Effective: April 30, 2024 IN THE EIGHTH JUDICIAL CIRCUIT OF FLORIDA STANDING CASE MANAGEMENT ORDER {AOSC20-23] THIS ACTION is before the court for case management pursuant to AOQSC20-23 {Amendment 10). Therefore, it is ADJUDGED that: 1. This case is provisionally designated as a general civil case. 2. TRIAL DATE: The projected date for a non-jury trial shall be the first regular trial term taking place one year after the date of filing. The projected date for a jury trial shall be the first regular trial term taking place eighteen months after the date of filing. A firm trial date will be established by the presiding judge when the case is at issue. Trial term dates for each civil division are published on the Eighth Judicial Circuit Court website at httos://circuit8.org/court- calendars/master-calendars/. In county court cases, any case redesignated by the trial court as a streamlined case, in cases where the parties request it, or in any other case the trial court deems it appropriate, the trial date may be adjusted to take piace sooner. Judges shall apply a firm continuance policy allowing continuances only for good cause shown. 3. SERVICE: Unless otherwise extended by court order for good cause shown, service of complaints should be completed within 120 days of filing. Requests for the addition of new parties shall be filed within 180 days of filing. 4, DISCOVERY: Fact and expert discovery shall be completed 60 days prior to the trial date set forth above. 5. PRETRIAL MOTIONS: Objections to pleadings and pretrial motions shall be resolved a minimum of 30 days prior to the trial date set forth above. Prior to filing ANY motion, counsel AO 3.09 Page Adi Standing Case Management Order Effective: April 30, 2021 filing the motion shall confer with opposing counsel by telephone or in person in a good faith attempt to resolve the motion. The motion shall contain a good faith statement reflecting the date and time of the conference with opposing counsel. A statement that counsel attempted to confer with opposing counsel is insufficient unless the good faith statement details the date and time of at least three attempts to confer that occurred within the one-month period immediately prior to the filing of the motion, 6. MEDIATION: The parties shall conclude mediation at least 90 days prior to the trial date set forth above. 7. Deadlines established herein shall be strictly enforced. “Lawyers must strictly comply with Florida Rule of General Practice and Judicial Administration 2.545(a), which requires lawyers to conclude litigation as soon as it is reasonably and justly possible to do so, and the pandemic alone is not a basis for a lawyer’s failure to prepare a case for trial or otherwise actively manage a case.” This order may be modified at such time that the case is determined to be at issue. Fla. R. Civ. P. 1.440. ORDERED in Alachua County, Florida, on April 23, 2021. a Ve I peed Mark W. Moseley, Chief Judge on behalf of all presiding Eighth Circuit civil judges | HEREBY CERTIFY that | have read and will comply with the foregoing standing order and shall cause it to be filed and served, contemporaneously with the complaint, on all named it Bb defendants. ki GMa Plaintiff or Plaintiff's Counsel Date AO 3.09 Page Adi Standing Case Management Order Effective: Apri! 30, 2021